In recent years, as the crypto market has increasingly attracted attention from all quarters, the demand for regulating the crypto market has become more and more urgent. Based on their own economy, financial system and strategic considerations, different countries and regions have successively introduced regulatory policies with their own characteristics. From the continuous game between the US SEC and crypto companies, to the EU's comprehensive roll - out of the Crypto - asset Markets Regulation (MiCA) bill, to the difficult balance between innovation and risk in emerging economies, the global crypto regulatory landscape is showing an unprecedented complexity and diversity. Now, let's unfold the crypto regulation world map together and explore the hidden veins under this global regulatory wave.

Policy Easing in Progress: A Panoramic View of the Crypto Regulation World Map

On the map, we divide the countries into four categories: business concentration areas, fully compliant, partially compliant and non - compliant. The criteria for judgment include the legal status of crypto - assets (50%), the regulatory framework and the implementation of laws and regulations (30%) and the implementation of exchanges (20%).

Asia

Greater China Region

Hong Kong, China

In Hong Kong, China, crypto - assets are regarded as "virtual assets" rather than currency and are regulated by the Securities and Futures Commission (SFC). For stablecoins, Hong Kong implements a licensing system. The Stable Coin Ordinance restricts licensed institutions from issuing Hong Kong dollar - denominated stablecoins. As for other tokens, NFTs are regarded as virtual assets, while governance tokens are regulated in accordance with the rules of "collective investment schemes".

In terms of the regulatory framework, Hong Kong revised the Anti - Money Laundering Ordinance in 2023, requiring crypto exchanges to obtain licenses. In addition, the Securities and Futures Commission (SFC) has also issued rules for virtual asset ETFs. The SFC is responsible for license issuance. At present, HashKey and OSL have been the first to obtain licenses, and more than 20 institutions are in the application process. In terms of exchange implementation, licensed exchanges are allowed to serve retail investors. It is worth noting that Bitcoin and Ethereum ETFs were listed in Hong Kong in 2024.

By actively embracing Web3 and virtual assets, especially allowing retail trading and launching virtual asset ETFs, Hong Kong aims to consolidate its position as an international financial center and form a sharp contrast with the strict ban in mainland China. The SFC of Hong Kong enforces exchange licensing, allows licensed exchanges to serve retail investors and has launched Bitcoin / Ethereum ETFs. Against the backdrop of the mainland China's comprehensive ban on crypto - currencies, Hong Kong has chosen a completely different path, actively building a clear and regulated virtual asset market. Allowing retail participation and launching ETFs are the key measures to attract global crypto capital and talent, enhance market liquidity and international competitiveness.

Taiwan, China

The Taiwan region of China takes a cautious attitude towards crypto - currencies and does not recognize their status as currency. However, it regulates them as speculative digital commodities and gradually improves the framework for anti - money laundering and security - token offerings (STOs).

Legal status of crypto - assets: The Taiwan region of China currently does not recognize crypto - currencies as currency. Since 2013, the stance of the Central Bank of Taiwan and the Financial Supervisory Commission (FSC) has been that Bitcoin should not be regarded as currency, but as a "highly speculative digital virtual commodity". For tokens such as NFTs and governance tokens, their legal status is not yet clear. However, in practice, NFT transactions require the declaration of capital gains tax. Security tokens are recognized by the FSC as securities and regulated under the Securities and Exchange Law.

Regulatory framework: Taiwan's Anti - Money Laundering Law regulates virtual assets. The FSC has ordered that since 2014, local banks are not allowed to accept Bitcoin and are not allowed to provide any services related to Bitcoin. For security - token offerings (STOs), Taiwan has specific regulations, which distinguish regulatory paths according to the amount of issuance (NT $ 30 million). The FSC also announced in March 2025 that it is drafting a law specifically targeting virtual asset service providers (VASPs), aiming to shift from a basic registration framework to a comprehensive licensing system.

License issuance: In 2024, the FSC introduced new rules under the Anti - Money Laundering Law, requiring VASPs to register with the FSC before providing any virtual - asset - related services (such as operating exchanges, trading platforms, transfer services, custody services or underwriting activities). Failure to register may result in criminal penalties. For STOs, the issuer must be a Taiwan - registered joint - stock company, and the STO platform operator must obtain a securities dealer license and have a paid - in capital of at least NT $ 100 million.

Mainland China

Mainland China has a comprehensive ban on the trading of crypto - assets and all related financial activities. The People's Bank of China believes that crypto - currencies disrupt the financial system and facilitate criminal activities such as money laundering, fraud, pyramid selling and gambling.

In judicial practice, however, virtual currencies have corresponding property attributes, and a consensus has basically been formed in judicial practice. In the field of civil law, precedents generally believe that virtual currencies have characteristics such as exclusivity, controllability and transferability in possession, similar to virtual goods, and recognize that virtual currencies have property attributes. Some precedents cite Article 127 of the Civil Code "If the law has provisions on the protection of data and network virtual property, it shall be followed" and refer to Article 83 of the "Minutes of the National Court Financial Trial Work Conference" "Virtual currencies have some attributes of network virtual property", determining that virtual currencies are a specific type of virtual property and should be protected by law. In the field of criminal law, recent cases included in the case library of the Supreme People's Court have also clearly stated that virtual currencies are considered property in the sense of criminal law and have property attributes in the sense of criminal law.

However, since 2013, banks in mainland China have been banned from engaging in crypto - currency business. In September 2017, China decided to close all domestic virtual currency exchanges within a specified time. In September 2021, the People's Bank of China issued a notice, comprehensively banning services related to virtual currency settlement and providing information about traders, and clarified that engaging in illegal financial activities will be subject to criminal liability. In addition, crypto - currency mines were closed and the opening of new mines was not allowed. It is also considered an illegal financial activity for overseas virtual currency exchanges to provide services to Chinese residents through the Internet.

Singapore

Legal status of crypto - assets: Singapore regards crypto - assets as "payment instruments / goods", mainly based on the provisions of its Payment Services Act. For stablecoins, Singapore implements a licensed issuance system. The Monetary Authority of Singapore (MAS) requires issuers to have a 1:1 reserve and conduct monthly audits. For other tokens, such as NFTs and governance tokens, Singapore adopts a case - by - case determination principle: NFTs are generally not regarded as securities, while governance tokens may be regarded as securities if they have dividend rights.

Crypto - currency regulatory framework: Singapore's Financial Services and Markets Act, promulgated in 2022, regulates exchanges and stablecoins. However, the newly effective DTSP regulations have greatly reduced the scope of license compliance, which may affect the offshore business of crypto projects and exchanges. The Monetary Authority of Singapore (MAS) usually issues three types of licenses to crypto companies: money exchange, standard payment and large - payment institutions. At present, more than 20 institutions have obtained licenses, including Coinbase. Many international exchanges choose to set up regional headquarters in Singapore, but these institutions will be affected by the new DTSP regulations.

South Korea

In South Korea, crypto - assets are regarded as "legal assets", but not legal tender, mainly based on the provisions of the "Special Financial Information Reporting and Utilization Act" (the "Special Financial Act"). At present, the draft "Digital Assets Basic Act" (DABA) is being actively promoted and is expected to provide a more comprehensive legal framework for crypto - assets. The current "Special Financial Act" mainly focuses on anti - money laundering regulation. For stablecoins, the DABA draft proposes to require their reserve transparency. As for other tokens, such as NFTs and governance tokens, their legal status is not yet clear: NFTs are currently regulated as virtual assets, while governance tokens may be included in the category of securities.

South Korea implements a real - name - based exchange licensing system. At present, five major exchanges, including Upbit and Bithumb, have obtained licenses. In terms of exchange implementation, the South Korean market is mainly dominated by local exchanges, and it is forbidden for foreign exchanges to directly serve South Korean residents. At the same time, the draft "Digital Assets Basic Act" (DABA) of South Korea is being promoted, which proposes to require stablecoin reserve transparency. This strategy not only protects domestic financial institutions and market share, but also facilitates regulatory authorities to effectively monitor domestic trading activities.

Indonesia

Indonesia is experiencing a shift in the regulatory authority of crypto - assets from the Commodity Futures Trading Regulatory Agency (Bappebti) to the Financial Services Authority (OJK), signaling more comprehensive financial regulation.

Legal status of crypto - assets: The legal status of crypto - assets in Indonesia is not yet clear. With the recent shift in regulatory authority, crypto - assets are classified as "digital financial assets".

Regulatory framework: Previously, Indonesia's Commodity Law regulated exchanges. However, the recently promulgated "OJK Regulation No. 27 of 2024" (POJK 27/2024) has transferred the regulatory authority of crypto - asset trading from Bappebti to the Financial Services Authority (OJK), and this regulation will come into effect on January 10, 2025. This new framework sets strict capital, ownership and governance requirements for digital asset exchanges, clearing houses, custodians and dealers. All licenses, approvals and product registrations previously issued by Bappebti remain valid as long as they do not conflict with current laws and regulations.

License issuance: The licensing authority has been transferred from Bappebti to OJK. The minimum paid - in capital for crypto - asset dealers is 1 trillion Indonesian rupiah, and at least 500 billion Indonesian rupiah of equity must be maintained. Funds for paid - in capital must not come from illegal activities such as money laundering, terrorism financing or financing of weapons of mass destruction. All digital financial asset trading providers must fully comply with the new obligations and requirements of POJK 27/2024 by July 2025.

Exchange implementation: Local exchanges such as Indodax are actively operating locally. Indodax is a regulated centralized exchange that offers spot, derivatives and over - the - counter (OTC) trading services and requires users to comply with KYC.

Thailand

Thailand is actively shaping its crypto - currency market by encouraging compliant trading and consolidating its position as a global financial center through tax incentives and strict licensing systems.

Legal status of crypto - assets: In Thailand, it is completely legal to own, trade and mine crypto - currencies, and profits are subject to tax in accordance with Thai law.

Regulatory framework: Thailand has enacted the Digital Assets Act. It is worth noting that Thailand has approved the exemption of capital gains tax on crypto - currency sales conducted through licensed crypto - asset service providers for five years, from January 1, 2025 to December 31, 2029. This measure aims to position Thailand as a global financial center and encourage residents to trade on regulated exchanges. The Securities and Exchange Commission (SEC) of Thailand is responsible for regulating the crypto market.

License issuance: The SEC of Thailand is responsible for issuing licenses. Exchanges must obtain official permission and register as a Thai limited or public company. License requirements include minimum capital (50 million baht for centralized exchanges and 10 million baht for decentralized exchanges) and directors, executives and major shareholders must meet the "fit and proper" standards. KuCoin has obtained an SEC license through acquisition.

Exchange implementation: Local exchanges such as Bitkub are active locally and have the highest crypto - currency trading volume in Thailand. Other major licensed exchanges include Orbix, Upbit Thailand, Gulf Binance and KuCoin TH. The SEC of Thailand has taken action against five global crypto exchanges, including Bybit and OKX, to prevent them from operating in Thailand because they have not obtained local licenses. Tether has also launched its tokenized gold digital asset in Thailand.

Japan

Japan is one of the earliest countries in the world to clearly recognize the legal status of crypto - currencies, and its regulatory framework is mature and prudent.

Legal status of crypto - assets: In the Payment Services Act, crypto - assets are recognized as "legal means of payment". For stablecoins, Japan implements a strict bank / trust monopoly system, requiring them to be pegged to the yen and redeemable, while explicitly prohibiting algorithmic stablecoins. As for other tokens, such as NFTs, they are regarded as digital goods, while governance tokens may be considered as "collective investment scheme interests".

Regulatory framework: Japan formally recognized crypto - assets as legal means of payment by amending the Payment Services Act and the Financial Instruments and Exchange Act (2020). The Financial Services Agency (FSA) is in charge of regulating the crypto market. The revised Payment Services Act also added the "domestic retention order" clause, which allows the government to require platforms to retain part of users' assets in Japan when necessary to prevent the risk of capital outflow. In terms of license issuance, the FSA is responsible for issuing exchange licenses, and there are currently 45 licensed institutions. Key requirements for obtaining a Japanese crypto - currency license include: having a legal entity and office locally, meeting the minimum capital requirements (more than 10 million yen, with specific capital holding regulations), complying with AML and KYC rules, submitting a detailed business plan and conducting continuous reporting and auditing.

Exchange implementation: The Japanese market is mainly dominated by local exchanges such as Bitflyer. International platforms usually need to enter the Japanese market through joint ventures (such as Coincheck).

Europe

EU

As one of the most complete and extensive judicial regulatory jurisdictions in the global crypto field at present, Europe is becoming the first stop for compliance for many crypto projects. The EU has demonstrated its leadership as a globally important judicial jurisdiction in the field of crypto - currencies by building a unified regulatory framework through the Markets in Crypto - assets Regulation (MiCA).

Legal status of crypto - assets: Under the MiCA framework, crypto - assets are defined as "legal means of payment, but not legal tender". For stablecoins, MiCA has implemented strict regulation, requiring them to have a 1:1 fiat - currency - pegged and fully - reserved, and only allowing licensed institutions to issue them. MiCA classifies stablecoins into asset - referenced tokens (ARTs) and electronic money tokens (EMTs) for regulation. For other tokens, such as non - fungible tokens (NFTs) and governance tokens, the EU adopts a classified regulatory approach: NFTs are generally regarded as "unique digital assets" and are exempt from securities rules, while governance tokens are regarded as securities according to their functions and the rights they confer. MiCA currently does not cover security tokens, NFTs and central bank digital currencies (CBDCs).

Regulatory framework: The EU passed the MiCA bill in June 2023, with the stablecoin rules coming into effect in June 2024 ahead of schedule and the bill fully effective on December 30, 2024. The bill applies to 30 countries in Europe, including the 27 EU member states and Norway, Iceland and Liechtenstein in the European Economic Area. MiCA aims to address legal ambiguity, stablecoin risks and insider trading issues, and to protect investors, maintain market integrity and financial stability through unified rules. It makes detailed provisions for the issuance of crypto - assets, the authorization of service providers, operations, reserve and redemption management, and anti - money laundering (AML) regulation. In addition, MiCA also integrates the travel rule of the Funds Transfer Regulation (TFR), requiring crypto - asset service providers (CASPs) to include sender and recipient information in each transfer to enhance traceability.

License issuance: MiCA adopts the "one - stop - shop" model, which means that CASPs only need to be authorized in one member state to operate legally within the jurisdiction of all member states, greatly simplifying the compliance process. CASPs must be authorized by their national competent authorities. License requirements include good reputation, capability, transparency, data protection and compliance with the minimum capital requirements stipulated in Annex IV of MiCA, which range from EUR 15,000 to EUR 150,000 depending on the type of service. CASPs are also required to have a registered office in an EU member state and at least one director who is a resident of the EU.

Stablecoin implementation: USDC and EURC issued by Circle have obtained MiCA compliance approval and are regarded as stablecoins in line with EU standards. Tether (USDT) has faced delisting by major exchanges such as Coinbase and Binance for its users in the EU region due to its failure to meet the strict stablecoin regulations of MiCA.

UK

After Brexit, the UK did not simply copy MiCA, but chose an independent but equally comprehensive regulatory path to maintain its competitiveness as a global financial center.

Legal status of crypto - assets: In the UK, crypto - assets are explicitly regarded as "personal property", a legal status confirmed in the Parliamentary Act of 2024. This act aims to provide digital assets with the same legal protection as traditional property, thereby enhancing the certainty of owners and traders. For stablecoins, the UK takes a prudent regulatory approach, requiring them to obtain approval from the Financial Conduct Authority (FCA), and the reserve assets must be held in custody separately. As for other tokens, such as NFTs, they are also regarded as property according to court precedents. The legal status of governance tokens is determined according to their specific use, and may be classified as securities or utility tokens.

Regulatory framework: The Financial Services and Markets Bill (2023) has included crypto - assets within the scope of regulation and revised the definition of "designated investments" in the Financial Services and Markets Bill (2000) to include crypto - assets. The Bank of England has also regulated stablecoins in parallel, regarding them